ee ee ee eee eee eee ee eee ee eee eee eee eee CIRCUIT COURT FOR HAMILTON COUNTY , State of Tennessee ADEBAYO KINGSLEY ADEEKO, ASHLEY ADEEKO, wo.__19 034 JURY DEMAND Plaintiffs, ~ (CHATTANOOGA METROPOLITAN AIPORT AUTHORITY, OFFICER DARRELL WRIGHT, OriceR JANE Doz, In their individual and official capacities as agents and employees of Chattanooga Metropolitan Airport Authority, and EAN HOLDINGS, LLC, d/b/a ‘NATIONAL CAR RENTAL, Defendants, COMPLAINT PLAINTIFFS, through counsel, for their causes of action will show the Court: Introduction: 1. This is an action for money damages brought pursuant to 42 U.S.C. §§ 1981, 1983 and 1988 to redress the deprivation of rights secured to the Plaintiffs by the Fourth Amendment and Fourteenth Amendment to the United States Constitution, 42 U.S.C. § 1981, and for violations of the laws of the State of Tennessee by the Defendants, 2. Plaintiffs aver that the individually named Defendants Officer Darrell Wright Wright”), and Officer Jane Doe (“Doe”) worked in unison to conduct an unreasonable seizure and unreasonable search of the Plaintifis' persons and property.(3/22/2019 FAT 10:26 FAR 425209670) Ham Co. Carcelt Court Mayenne 7 = A 3. Plaintiffs further aver that Wright, and Doe worked in unison with the private corporate defendant named herein to deprive Plaintiff Adebayo Kingsley Adecko (“Adebayo”) of his rights to make and enforce a contract for a rental car, and impaired Adebayo’s ability to enter into suid contract through color of state law. 4, Plaintiffs aver that Wright and Doe, failed to intervene and prevent one another from their respective conduct that resulted in an unreasonable search and unreasonable seizure of ‘the Plaintiffs’ persons and property. 5. Plaintiffs also maintain that Wright and Doe committed these violations and torts 5 a result of policies, customs, and/or procedures of the Chattanooga Metropolitan Airport Authority “CMAA”). 6. Plaintiffs also maintain that EAN Holdings, LLC, d/b/a National Car Rental (CEAN”) deprived Adebayo of his right to engage into and enforce a contract for a rental car ‘based upon his race. ite In addition, Plaintifiis aver that the individual defendants and EAN subjected Plaintiffs to mental anguish and emotional distress. Jurisdiction and Venue: 8 ‘This is an action to redress the deprivation of rights secured to the Plaintiffs by the Fourth, and Fourteenth Amendments to the United States Constitution enforceable through 42 US.C. § 1983. This is also an action by Adebayo to redress the deprivations of rights secured to him by 42 U.S.C. § 1981. Finally, this is an action by Plaintifis for violations of Tennessee state Jaw committed by the Defendants either jointly or separately. 9. Thus, as to the § 1983 claims, this Court is vested with concurrent original jurisdiction pursuant to the authority stated in Haywood v. Drown, 556 U.S. 729, 731 (2009) and oeOSi2ef 2019 PRT 10627 FAR 422205670) Bam Co. CArcult Court laoes/e2z oe =~ Poling v. Goins, 713 $.W.2d 305 (Tenn. 1986). As to the claims under 42 U.S.C. § 1981, this Court has concurrent original jurisdiction with the federal courts to enforce the rights created by federal law pursuant to the authority stated in Chatles Dowd Box Co. v. Courtney, 368 U.S. 502, 507-08 (1962). This Court is vested with original jurisdiction over the state claims pursuant to TENN. CODE ANN. § 16-10-101, et seq. 10. Venue is proper in this Court pursuant to TENN. CODE ANN. § 20-4-102. All acts complained of ocourred within Hamilton County. 8 Plaintiffs are residents of Hamilton County, Tennessee. b. To the best of Plaintiffs’ knowledge and belief, the individual defendants are residents of or conduct their duties as agents of CMAA within Hamilton County, Tennessee, ©, EAN is registered with the Tennessce Secretary of State asa foreign limited Tiability company engaged in the business of car rentals to members of the public within Hamilton County, Temessee. EAN’s principle address is 600 Corporate Park Drive, St. Louis, MO. BAN?s registered ageat for service of process is CT Corporation, 300 Montvue Rd., Knoxville, TN 37919, and may be served with a copy of the summons and complaint there. 4, CMAA is a municipal airport authority authorized by the Chattanooga City Charter § 15.2 and appropriate Tennessee Code provisions including TENN. CODE. ANN. § 42-3-103 and operates an airport pursuant to TENN, CODE ANN. § 42-4- 101, et seq. CMAA is situated in Hamilton County, Tennessee, and is a public entity that maintains a police department performing law enforcement functions on the grounds of MAA.